Elizabeth Holland, director of the Health Information Technology Initiatives Group for the Office of E-Health Standards & Services, sat down with SearchHealthIT to discuss the rollout of meaningful use audits. In part two of the interview, Holland considers the impact potential changes to the law might have on future rulemaking. Part one is here.
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CMS put out a fact sheet about meaningful use audits, as well as documentation guidance, which at some points suggests providers and hospitals attesting for incentive payments take screenshots to prove compliance with some measures, such as drug-drug/drug-allergy interaction checks. What advice do you have for incentive program participants who want to be ready to go in aggregating all this documentation?
Elizabeth Holland: This was one of the challenges, because different EHR systems act a little differently, and we're finding that's part of the issue here. With some EHRs, it's easy to get the documentation out, and with others it's more challenging. In that fact sheet we included what we suggest you have for documentation; it's not saying this is what you must have or this is the only thing you could have. It's just giving suggestions so that people can have an idea of what we're looking for.
We've been trying to work really closely with [the auditor's managers] so they're going after the clinical information or whatever the meaningful use measures require, and not just trying to be a bean counter.
Anything that really validates your EHR attestation. So if you pull data together into a file to get the information together, [and] if you have all the documentation you used when you filled out the attestation forms -- that would be really helpful.
Sounds like a job for the Office of the National Coordinator for Health IT (ONC) in future EHR meaningful use certification standards?
Holland:Yes. We're hoping to do that. We work very closely with [the] ONC and this is just the beginnings of the findings coming in, so hopefully over the next few months there will be a lot more sharing of information with [the] ONC -- and even with the public -- about what seems to be big problem areas for people, and how people can have [the kinds] of documentation they need to support their attestation.
We're doing this because we care about the program and we care that we're paying incentives appropriately, but we also don't want to scare people off so they don't participate at all. We don't want to scare them away.
I get that. But screenshots? On one hand, it's electronic health records; of course there is no paper. On the other hand, there's got to be a better way.
What happens when an eligible provider or eligible hospital doesn't pass the audit? Is it like a Joint Commission survey where they have a period of time to fix the situation of bad findings, or is it game over?
Holland:They have to return the money.
Figliozzi and Company is the firm contracting for meaningful use audits. What can you tell me about the company and what made them earn the contract?
Holland:I didn't [award] the contract, so I don't know. I know it was handled through the regular contracting mechanisms we use, and I don't have information on how many firms bid or anything like that, unfortunately.
In several conferences, we've heard hospital attorneys, or in one case, CIOs who went through a meaningful use audit, talk about the experience. So far the reviews have been mixed; the general consensus being that the company sent financial/accounting types that were not as familiar with health care workflows as the hospital expected. Can CMS refine this process and give auditors more direction?
Holland:Yes. As we're moving forward, things are improving tremendously. In the beginning there was a lot of not understanding what we needed. My folks are the program folks, but the people overseeing the audits are more of the financial folks, so we've been trying to work really closely with them so they're going after the clinical information or whatever the meaningful use measures require, and not just trying to be a bean counter.
So those reading this article can rest assured that the process is evolving as you go along.
Holland:Yes, absolutely. There's going to be major refinement coming as we continue to learn more.
The EHR Improvement Act is being debated in Congress; who knows if it will go anywhere. What does CMS do in this situation? Do you have informal discussions about what happens if it passes, do you take action, or do you just wait until it gets to the president's desk?
Holland:It varies. Sometimes we're asked for extensive input; sometimes we're not. I know about this bill, but we have not been asked to give extensive input. It is interesting that they're talking about it, because it was something we talked about in our stage 2 rulemaking, but it wasn't one of the exceptions being finalized. We had a lot of comments on it, and there wasn't a lot of generalized support for adding it.
[The bill is] interesting. We definitely follow anything Congress tells us to do, but I don't know if it has any legs or not.